In the world of youth sports, few moments are as exhilarating as a home run in a championship game. For 12-year-old M.R. of Haddonfield, New Jersey, that moment became the center of a legal controversy that captured national attention and raised important questions about fairness, due process, and the role of the courts in youth athletics.
The Incident: A Celebratory Bat Flip
On July 16, 2025, during the final inning of the New Jersey Section 4 Championship of the Little League Baseball Tournament, M.R. hit a two-run home run cementing a victory for his team and a trip to the New Jersey State Championship Tournament, which would commence eight days later. In a moment of pure excitement, he celebrated with a bat flip – a gesture increasingly common in professional baseball and even featured on Little League’s social media accounts and official website. However, citing “safety concerns” and “unsportsmanlike conduct,” the umpire ejected M.R. from the game. Per Little League rules, any ejection of a player automatically triggers a one-game suspension. As such, M.R., one of the best players on the defending state champion Haddonfield Little League, would miss the opening game of the state tournament, a tournament that could lead to the Little League World Series in Williamsport, Pennsylvania. The Rocco family was without any recourse from Little League but believed that the umpire’s decision to eject M.R. was arbitrary and unjust, so they turned to the legal system for relief after settlement discussions with Little League stalled.
The Legal Claims: Breach of Implied Contract and Breach of the Implied Covenant of Good Faith and Fair Dealing
Represented by Fox Rothschild LLP attorneys Brian A. Berkley and Michael Fitzgerald, Joesph Rocco, as parent and natural guardian of M.R., filed for an emergency temporary restraining order in the Superior Court, General Equity Division, of Gloucester County, New Jersey. Their argument centered around two claims:
- Breach of Implied Contract: There was an implied contract between Plaintiff and Little League. Namely, (i) Plaintiff paid dues to Little League in exchange for M.R. being able to play Little League baseball, and (ii) both M.R. and Little League agreed to abide by the Little League rules. By ejecting M.R. for bat flipping without justification, Little League was in breach of the contract because there was no express rule against bat flipping.
- Breach of the Covenant of Good Faith and Fair Dealing: Every contract carries with it an implied covenant of good faith and fair dealing. Little League breached this implied covenant by applying its rules in an arbitrary, unreasonable, and capricious manner. That is, Little League promoted bat flipping from other Little League players on its website and social media accounts but ejected (and suspended) M.R. for performing the same act.
The Court agreed, and the Honorable Robert Malestein granted the restraining order. In granting the restraining order, Judge Malestein held that, at the very least, there was an implied contract between the parties, and Little League breached this contract by ejecting M.R. without pointing to any express Little League rule. Additionally, Judge Malestein held that Little League was in breach of the implied covenant of good faith and fair dealing by applying the Little League rules in an arbitrary manner, i.e., Little League promoted bat flips from some players on its social media accounts but ejected M.R. for doing the same act. The ruling came eight days after the incident occurred, forty-eight hours after the complaint was filed, and just hours before the first pitch of the game in which M.R. was to be suspended.
Broader Implications: Youth Sports and the Law
- Clarity and Consistency in Rules: Private organizations expose themselves to litigation if they rely upon unclear rules or try to apply the rules in an arbitrary, unreasonable, or capricious manner.
This post is authored by Fox Rothschild Partner Brian Berkley and Associate Mike Fitzgerald.
